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05000259/FIN-2018002-04Browns Ferry2018Q2Licensee Identified Non-Cited Violation

LER 05000259, 260, 296/2018-003-00 identified a violation of 10 CFR 50.48(c)(4)(iii). This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a Non-Cited Violation, consistent with Section 2.3.2 of the Enforcement Policy. 

Violation: 10 CFR 50.48(c)(4)(iii) Fire Protection required, in part, that the licensee maintain fire protection defense in depth (post-fire safe shutdown capability). Contrary to the above, from October 28, 2015 until March 10, 2018, the C3 Emergency Equipment Cooling Water (EECW) pump did not have the Fire Protection Plan required backup control panel function. Significance/Severity: Using IMC 0609 Appendix F, the violation was screened to green following a risk analysis performed by the licensee that a NRC Senior Risk Analyst reviewed and agreed was correctly performed. Corrective Action Reference(s): CR 1394604
05000259/FIN-2017003-02Browns Ferry2017Q3Failure to Maintain Intake Building Flood BarrierAn NRC- identified NCV of Technical Specification (TS) 5.4.1, Procedures, was identified for the failure to follow procedure MCI -0-023- PMP003, Emergency Equipment Cooling Water (EECW) and Residual Heat Removal Service Water Pump (RHRSW) Removal and Reinstallation, Revision 22. The performance deficiency is more than minor because it affected the Mitigating Systems cornerstone attribute of Equipment Performance and adversely affected the cornerstone objective. A detailed risk evaluation by a regional SRA determined the finding was Green . The licensee entered the violation into the CAP as CR 1338684. The finding had a cross cutting aspect in the Avoid Complacency component of the Human Performance area because the maintenance staff chose to not refer to a previously related condition report (CR) (PER 599190) or the maintenance procedure that were corrective actions for a previous NRC finding. (H.12).
05000341/FIN-2016001-11Fermi2016Q1Licensee-Identified ViolationTechnical Specification 3.7.2, Emergency Equipment Cooling Water (EECW) / Emergency Equipment Service Water (EESW) System and Ultimate Heat Sink (UHS), Required Actions, Note 1, states: Enter applicable Conditions and Required Actions of LCO 3.8.1, AC (Alternating Current) Sources Operating, for diesel generators made inoperable by UHS. Technical Specification 3.8.1, Condition A is required when one EDG is inoperable and Condition B is required when both EDGs in one division are inoperable. Technical Specification 3.8.1, Required Actions A.1 and B.1, state: Perform SR 3.8.1.1 for operable offsite circuit(s) within 1 hour and once per 8 hours thereafter, and TS 3.8.1, Required Action A.3, states: Verify the status of CTG 11-1 once per 8 hours. Contrary to the above, on July 28, 2015, with the Division 2 UHS reservoir inoperable, the licensee failed to enter the applicable conditions and required actions of TS 3.7.2 and subsequently, failed to enter TS 3.8.1 for both Division 2 EDGs made inoperable by an inoperable UHS reservoir. Consequently, with both EDGs in one division inoperable, the licensee failed to complete TS 3.8.1, Required Actions A.1 and B.1, to perform SR 3.8.1.1 for operable offsite circuits within 1 hour and once per 8 hours thereafter, and also failed to complete TS 3.8.1, Required Action A.3, to verify the status of CTG 11-1 once per 8 hours. In addition, with the required actions and associated completion times of Conditions A and B not met, the licensee failed to complete TS 3.8.1, Required Action G, to be in Mode 3 within 12 hours. The failure to complete these TS required actions is a violation of TS 3.8.1. The issue was determined to be of very low safety significance (Green) because it did not represent an actual loss of function of a single train (or division) for greater than its TS allowed outage time. The licensee entered this violation into its CAP as CARD 15-25243.
05000259/FIN-2015004-03Browns Ferry2015Q4Corrective Actions For 2012 Flooding WalkdownsThe inspectors identified an URI associated with potentially deficient flood barrier penetrations in the RHRSW rooms. The inspectors determined that several of the conditions had been previously identified by the licensee and entered into the CAP in November of 2012; however, the conditions had not yet been corrected.Description: Initially, the inspectors identified a potential flood barrier bypass in the B RHRSW room associated with a 2 inch diameter pipe that had significantly corroded an open area through the pipes wall. The inspectors reviewed the licensees response and discovered that an immediate operability determination was hampered because the pipe and valves were not marked or labeled and could not be located on any reviewed drawings. The issue was closed before resolving whether operability of the compartments pumps were affected. Upon additional questioning by the inspectors, the licensee reinitiated investigation of the issue. Since the pipes penetration points could not be readily determined, the licensee closed a manual isolation valve that was discovered upstream of the break in the pipe. Closure of the valve eliminated the potential immediate operability concern. The inspectors also identified that three other previously identified conditions had not been corrected in the B RHRSW room: 1) The B emergency equipment cooling water (EECW) strainer backwash valve conduit was severed where it penetrated the floor of the room, 2) There was an unsealed gap between a conduit sleeve and the enclosed conduit for powering the B1 RHRSW pump, 3) There was a 1/4 inch by 3/8 inch hole in a rubber boot at the B EECW discharge pipe floor penetration. Initial evaluations by the licensee determined that the first condition did not bypass the flood barriers and that the other two would potentially introduce flood water into the compartment at rate of 35 gallons per minute. This amount of inleakage was within the available pumping capacity of a single compartment sump pump and was not an immediate operability concern. However, the licensee has not yet evaluated the aggregate effect of all of the conditions concurrently. Because it is not yet clear whether the identified conditions could allow flood waters to bypass the RHRSW compartment flood barriers, more information is necessary to properly evaluate the licensees past operability evaluations, and the adequacy of the licensees corrective actions. Based on the available documentation of the walkdowns and corrective action documents, it was not clear to the inspectors how the licensee justified the reclassification of the conditions from initially unacceptable status to an indeterminate status and then finally to essentially acceptable status. Future inspection is required to determine if a more than minor performance deficiency or violation exists associated with these issues. Initial reviews have not identified any immediate safety concerns associated with the identified conditions. This issue has been entered in the licensees corrective action program as CRs 1070658, 1075911 and 1119892. (URI 05000259/260/296/2015-004-03, Corrective Actions For 2012 Flooding Walkdowns). These activities constituted four focused annual inspection samples, as defined in Inspection Procedure 71152. Documents reviewed are listed in the attachment.
05000341/FIN-2015003-03Fermi2015Q3Failure to Establish Correct Classification and Preventive Maintenance for Reactor Recirculation Pump Flow SwitchesA finding of very low safety significance with an associated Non-Cited Violation of Title 10 of the Code of Federal Regulations (10 CFR) 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants," was self-revealed on March 19, 2015, when the reactor recirculation pump A seal cooling water flow switch failed, resulting in a leak of Reactor Building closed cooling water and emergency equipment cooling water into the drywell and a subsequent reactor recirculation pump trip. The reactor recirculation pump seal cooling water flow switch was incorrectly classified in the licensees preventive maintenance program and did not have appropriate preventive maintenance tasks assigned to prevent its failure. The licensee replaced the failed flow switch prior to plant start up from the forced outage. Corrective actions to prevent recurrence for this event include replacing the recirculation pump seal cooling water flow switches with a more robust design that do not have glass tubes, thus eliminating the failure mechanism. The finding was of more than minor safety significance because it was associated with the Equipment Performance attribute of the Initiating Events Cornerstone and adversely affected the cornerstone objective of limiting the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, the reactor recirculation pump seal cooling water flow switch failure caused a loss of cooling water flow to a reactor recirculation pump that subsequently resulted in loss of the pump and single loop operation. In addition, the finding was sufficiently similar to Inspection Manual Chapter 0612, "Power Reactor Inspection Reports," Appendix E, "Examples of Minor Issues," Example 7(d), in that this violation of 10 CFR 50.65(a)(2) had a consequence such that "(a)n actual failure had occurred with the non-scoped component causing a transient/scram." The finding was determined to be a licensee performance deficiency of very low safety significance during a quantitative Significance Determination Process review since the delta core damage frequency was determined to be less than 1.0E-6/year. The inspectors concluded this finding affected the cross-cutting area of problem identification and resolution and the cross-cutting aspect of identification (IMC 0310, P.1). Specifically, licensee personnel had opportunities through execution and analysis of its preventive maintenance program to ascertain the effect the recirculation pump seal flow switch failure would have on the closed cooling water systems that connect to the component.
05000341/FIN-2015008-01Fermi2015Q1Failure to Translate TS 3.7.4 Requirements Correctly into Plant ProceduresThe inspectors identified a finding of very-low safety significance (Green), and an associated NCV of Title 10, Code of Federal Regulations (CFR) Part 50, Appendix B, Criterion III, Design Control, for the licensees failure to ensure instructions in plant procedures met the requirements as specified in the Technical Specifications (TSs). Specifically, the licensee failed to ensure that the caution statements as specified in the system operating procedures regarding the operability of the control center chillers when their associated Emergency Equipment Cooling Water Temperature Control Valve (TCV) was not in AUTO incorporated all the applicability modes for TS 3.7.4. The licensee entered this finding into their Corrective Action Program (CAP) as CARD 15-20790, and intended to revise the affected procedures to accurately translate TS 3.7.4 mode and plant conditions applicability requirements. The performance deficiency was determined to be more than minor because, if left uncorrected, it would have the potential to lead to a more significant safety concern. Specifically, the licensee could potentially consider the control center heating, ventilation, air conditioning system operable during movement of recently irradiated fuel assemblies and operations with potential for draining reactor vessel conditions while th TCV was not in the Updated Final Safety Analysis Report described AUTO design function and, therefore, challenged the control center habitability. The finding screened as of very-low safety significance (Green) because the finding did not represent a degradation of the radiological barrier function, or represent a degradation of the control room barrier function against smoke or toxic atmosphere. The inspectors did not identify a cross-cutting aspect associated with this finding.
05000341/FIN-2014003-03Fermi2014Q2Mis-Positioned Control Switch Inadvertently Rendered the Division 2 EECW System and Supported Systems InoperableA finding of very low safety significance with an associated non-cited violation of Technical Specification 5.4.1.a was self-revealed on February 6, 2014, when the Division 2 emergency equipment cooling water (EECW) system and its supported systems were inadvertently rendered inoperable. Control Room operators incorrectly positioned the Division 2 EECW isolation override switch to manual override while attempting to place the system in its normal standby configuration, disabling the systems automatic initiation function. The licensee promptly restored the affected systems to an operable status by returning the override switch back to normal. The issue was entered into the licensees corrective action program for evaluation and additional corrective actions. The finding was of more than minor significance since it was associated with the human performance attribute of the Mitigating Systems Cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the mis-positioned control switch rendered the Division 2 EECW system and its supported systems inoperable. The finding was determined to be of very low safety significance during a detailed quantitative Significance Determination Process review since the delta core damage frequency was determined to be less than 1.0E-7/year using the NRC Standardized Plant Analysis Risk model. The inspectors concluded this finding affected the cross-cutting area of human performance since adequate licensee personnel work practices did not support successful human performance (H.12). Specifically, human error prevention techniques, such as pre-job briefing and peer checking, were not adequately used to ensure that the correct procedure section was performed.
05000259/FIN-2013005-01Browns Ferry2013Q4Failure to Document Service Water Freeze Protection DeficienciesThe NRC identified a non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Procedures, for the licensees failure to implement 0-GOI-200-1, Freeze Protection Inspection. Specifically, the licensee failed to enter freeze protection discrepancies into the corrective action program as part of the Freeze Protection Discrepancy List per 0-GOI-200-1 for the residual heat removal service water (RHRSW) and emergency equipment cooling water (EECW) systems. As a corrective action, the licensee entered the required deficiencies onto the Freeze Protection Discrepancy List. The licensee has entered this issue into their corrective action program as problem evaluation reports 800190 and 821426. The finding was more than minor because, if left uncorrected, the performance deficiency would have the potential to lead to a more significant safety concern, in that the intake room piping would continue to be exposed to freezing temperatures without adequate freeze protection which could affect RHRSW and EECW systems ability to perform their safety functions. The inspectors performed a Phase 1 screening in accordance with IMC 0609, Significance Determination Process, Appendix A, Exhibit 1, Initiating Event screening question E, and determined the finding was of very low safety significance (Green) because it did not impact the frequency of an internal flooding event. The cause of this finding has a cross-cutting aspect in the Work Practice component of the Human Performance area, because the licensee failed to define an effectively communicate expectations regarding procedural compliance and tha personnel follow procedures. (H.4(b))
05000259/FIN-2013007-04Browns Ferry2013Q2Failure to Adequately Identify, Evaluate, and Correct the EECW Strainers Degraded/Nonconforming ConditionThe team identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to promptly identify and take corrective actions to address a non-conforming condition adverse to quality related to three faulted strainers in the safety related Emergency Equipment Cooling Water system. This was a performance deficiency. The licensee initiated Problem Evaluation Report 677627 to perform a new operability evaluation since the operability evaluation in Problem Evaluation Report 208636 was found to be inadequate. The licensee concluded that there were no current operability issues. The performance deficiency was determined to be more than minor because it affected the Equipment Performance attribute of the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and capability of the core spray system to respond to initiating events, in that, if left uncorrected could result in the plant not being able to sustain short-term heat removal under specific conditions. The team used Inspection Manual Chapter 0609, Significance Determination Process, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, and determined that the finding was of very low safety significance (Green) because the finding was not a design deficiency resulting in the loss of functionality or operability. The team evaluated the finding for cross-cutting aspects and determined the finding was associated with the corrective action program component of the problem identification and resolution area, because the licensee did not perform a thorough evaluation of identified problems such that the resolutions addressed the underlying causes and extent of condition.
05000259/FIN-2013011-14Browns Ferry2013Q2Failure to Implement an Adequate Test Program for RHRSWS and EECSThe team identified a non-cited violation of 10CFR50, Appendix B, Criterion XI, Test Control, because the licensee did not establish a test program for Residual Heat Removal Service Water (RHRSW) and Emergency Equipment Cooling Water (EECW) pumps such that the test adequately demonstrated the pumps would perform satisfactorily in service. Specifically, BFN did not perform RHRSW/EECW pump performance testing such that it adequately accounted for river water temperature impact on the pump lift, which affected pump flow and vibration performance. The test program did not account for changes to pump lift caused by river water temperature changes; as a result the test program did not adequately monitor pump and system performance and degradation. The licensee completed a prompt operability determination verifying that the pumps remained operable and documented the issue in PERs 730497 and 741036. The Finding was more than minor because at affected the Mitigating System Cornerstone and if left uncorrected, could become a more significant safety concern. The team determined the Finding was of very low safety significance because it was not a design or qualification deficiency, and it did not result in an actual loss of one or more trains of the RHRSW or EECW systems and/or their function. The Finding had a crosscutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because the licensee did not to thoroughly evaluate the changes in RHRSW and EECW pump performance such that the resolution addressed the causes and extent-of-condition.
05000259/FIN-2013002-01Browns Ferry2013Q1Failure to Implement Preventive Maintenance ProgramA self-revealing Apparent Violation (AV) of 10 CFR 50 Appendix B, Criterion V, Instructions, Procedures, and Drawings, was identified for the licensees failure to establish an adequate preventive maintenance program as required by procedure NPG-SPP-06.2, Preventive Maintenance. Specifically, the Residual Heat Removal Service Water Pump D1 Cross-Tie to Emergency Equipment Cooling Water Valve (0-FCV-067-0048), was not maintained in a manner that ensured it would perform its design function. The failed valve was replaced on January 16, 2013, with a new valve with a stainless steel disk. Further corrective actions were planned to develop adequate preventive maintenance activities for this valve. The licensee entered this issue into their corrective action program as PER 671314. This finding was determined to be more than minor because it was associated with the Protection Against External Events (fires) attribute of the Mitigating Systems cornerstone objective and adversely affected the cornerstone objective to ensure availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences (i.e. core damage). Specifically, the 0-FCV-067-0048 valve failed and could not perform its isolation function credited in the safe shutdown analysis. Because the finding could not be screened as very low safety significance (Green), nor its safety significance determined prior to issuing the inspection report, it is being characterized as To Be Determined (TBD). The cause of this finding was directly related to the cross-cutting aspect of Appropriately Coordinating Work Activities in the Work Control component of the Human Performance area, because maintenance activities for 0-FCV-067-0048 were more reactive than preventive.
05000341/FIN-2012004-03Fermi2012Q4Failure to Perform ASME Inservice Testing Comprehensive Pump Test RequirementA finding of very low safety significance and an associated NCV of 10 CFR 50.55a(f), Inservice testing requirements, and 10 CFR Part 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, was identified by the NRC inspectors. Specifically, the licensee failed to perform a required comprehensive pump test for division 1 and 2 emergency equipment cooling water makeup pumps within 2 years of the start of the third inservice testing interval. The third inservice testing interval commenced on February 17, 2010, and included a requirement to perform a comprehensive pump test for the division 1 and 2 emergency equipment cooling water makeup pumps within two years and every two years thereafter. The required comprehensive pump tests were not performed prior to February 17, 2012. The finding was determined to be more than minor because the finding was associated with the configuration control attribute of the Mitigating Systems Cornerstone and impacted the cornerstone objective of ensuring the capability of systems to prevent undesirable consequences (i.e., core damage). This finding was determined to be of very low safety significance because, following IMC 0609, Appendix E, Table 4a, Characterization Worksheet for Initiating Events, Mitigating Systems, and Barrier Integrity Cornerstones, all questions were answered no. This finding has a cross-cutting aspect in the area of Human Performance, Decision Making, supervisory and management oversight aspect because the licensee failed to appropriately oversee the development and implementation of the comprehensive pump testing.
05000259/FIN-2012003-01Browns Ferry2012Q2Failure to Maintain Flood Barrier Results in Inoperable Safety Related PumpsAn NRC-identified non-cited violation (NCV) of the Technical Specifications 5.4.1.a was identified for the licensees failure to maintain an Emergency Equipment Cooling Water (EECW) pump flood barrier in accordance with written procedures which resulted in the inoperability of two other safety related pumps. The licensee immediately restored the flood protection configuration of the C Residual Heat Removal Service Water (RHRSW) pump room by properly re-installing the flood protection cover and permanently stenciled the aluminum plate with the required procedure for installation. The licensee entered this issue into their corrective action program as PER 532050. The finding was more than minor because it was associated with the Mitigating Systems cornerstone attribute of Protection Against External Events, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of RHRSW pumps to perform their intended safety function during a design basis flooding event. Specifically, the improper re-installation of an external flood protection cover resulted in the inoperability of two Residual Heat Removal Service Water (RHRSW) pumps. The significance of this finding was evaluated in accordance with the IMC 0609 Attachment 4, Phase 1- Initial Screening and Characterization of Findings, which required a Phase 3 analysis because the finding involved the degradation of equipment designed to mitigate a flooding event and it was risk significant due to external initiating event core damage sequences. The finding was determined to be Green because of the short exposure time, and the low likelihood of the flood. The cause of this finding was directly related to the cross cutting aspect of Supervisory Oversight in the Work Practices component of the Human Performance area, because of the foremans assumption that workers knew to restore the flood protection cover to meet procedural requirements without a formal pre-job brief (H.4(c)).
05000259/FIN-2011003-01Browns Ferry2011Q2Failure to Take Corrective Actions to Preclude a Repetitive Functional Failure of an EDG due to Excessive Heat Exchanger FoulingA self-revealing non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, was identified for the licensees failure to take prompt corrective actions to preclude repetition of a significant condition adverse to quality (SCAQ) that resulted in the loss of a emergency diesel generator (EDG) safety function due to excessive heat exchanger fouling. On August 4, 2010 the licensee identified a SCAQ due to excessive fouling of the Unit 1/2 D EDG heat exchangers which resulted in a functional failure of the D EDG. Prompt corrective actions were not taken to preclude repetition because on June 5, 2011, excessive fouling was identified on the 3D EDG heat exchangers which resulted in a functional failure of the 3D EDG. Corrective actions taken by the licensee included cleaning and returning the 3D EDG heat exchangers to an operable status, and increasing monitoring of emergency equipment cooling water (EECW) cooling flow to all the EDG heat exchangers from weekly to every two days. The licensee entered this issue into their corrective action program as problem evaluation report (PER) 381569. This finding was determined to be more than minor because it was associated with the Mitigating Systems Cornerstone attribute of Equipment Performance, and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). Specifically, the excessive fouling of the 3D EDG heat exchanger was a functional failure and resulted in unplanned unavailability of the 3D EDG. In accordance with Inspection Manual Chapter (IMC) 0609 Attachment 4, Phase I - Initial Screening and Characterization of Findings, this finding was determined to be of very low safety significance because it did not represent an actual loss of safety function of a single train for more than its technical specification allowed outage time of seven days, or screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The cause of this finding was directly related to the cross-cutting aspect of Maintaining Long Term Plant Safety (Equipment Issues) in the Resources component of the Human Performance area because of the licensees failure to minimize the duration of a longstanding degraded equipment issue related to relic clam shells in the EECW system which resulted in a repetitive functional failure of an EDG due to excessive heat exchanger fouling.
05000259/FIN-2010006-01Browns Ferry2010Q3Failure To Correct The EECW Valves Throttled Below Analyzed ConditionThe inspectors identified a non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to adequately evaluate and take prompt corrective actions to address a condition adverse to quality related to two Emergency Equipment Cooling Water (EECW) system flow control valves determined to have been throttled below the analyzed 0.125 inch gap for a period of approximately three months. This condition restricted the flow to the cooler due to flow blockage which could have resulted in inoperability of the downstream safety-related Core Spray (CS) pump room heat exchangers. This finding was entered into the licensees corrective action program as PER 257029. The inspectors determined that the licensees failure to promptly address an identified deficiency associated with safety related equipment was a performance deficiency. The performance deficiency was determined to be more than minor because it was associated with the Equipment Performance attribute of the Mitigating Systems cornerstone and adversely affects the cornerstone objective to ensure the availability, reliability, and capability of the Core Spray system to respond to initiating events to prevent undesirable consequences; (i.e., core damage) , since it resulted in 2 valves in the core spray system remaining throttled below their analyzed seat to disc clearance for several months after the licensee became aware of this condition, thus subjecting these valves to an increased likelihood of clogging with debris and affecting the reliability of the system. The inspectors determined that the finding was of very low safety significance because the finding was not a design deficiency, did not result in an actual loss of system or single train function, and was not potentially risk significant due to external events. The inspectors determined that this finding directly involved the cross-cutting area of Problem Identification and Resolution, component of the Corrective Action Program and aspect of Through Evaluation of Identified Problems because the licensee did not perform a thorough evaluation of identified problems such that the resolutions address causes and extent of conditions.
05000259/FIN-2010002-01Browns Ferry2010Q1Failure to Effectively Maintain Performance of the A3 EECW Pump as Required by 10 CFR 50.65(a)(2)The inspectors identified a noncited violation of 10 CFR 50.65(a)(2) for failure to demonstrate that the performance of the A3 Emergency Equipment Cooling Water (EECW) pump was effectively controlled by preventive maintenance (PM) such that the pump remained capable of performing its intended function. Also due to inadequate evaluations performed after the A3 EECW pump exceeded its Maintenance Rule a(2) performance criteria, goal setting and monitoring were not established as required by paragraph a(1) of the Maintenance Rule. The licensee subsequently declared the EECW system in (a)(1) status and was in the process of developing the required goals and monitoring plan. This issue was entered into the licensees corrective action program as problem evaluation report 223404. The finding was determined to be of greater than minor significance because it was associated with the Equipment Performance attribute of the Mitigating Systems Cornerstone, and adversely affected the cornerstone objective of ensuring availability and reliability of systems designed to respond to initiating events to prevent undesirable consequences. More specifically, the licensee failed to demonstrate effective control of EECW system availability through appropriate PM. According to NRC Inspection Manual Chapter 0609.04, Phase I - Initial Screening and Characterization of Findings, this finding was determined to be of very low safety significance because it did not lead to an actual loss of a system safety function orscreen as potentially risk significant due to a seismic, flooding, or severe weather initiating event. The cause of this finding was directly related to the cross cutting aspect of Thorough Evaluation of Identified Problems in the Corrective Action Program component of the Problem Identification and Resolution area, because the licensee did not adequately evaluate the causes of the A3 EECW pump unavailability and thereby failed to correctly determine the impact on the 10 CFR 50.65(a)(2) unavailability performance criteria (P.1(c))
05000259/FIN-2009008-02Browns Ferry2009Q4Violation of 10CFR50, Appendix B, Criterion V for Inadequate Procedure for Emergency Equipment Cooling Water System Flow BalancingThe inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, for the failure to provide adequate guidance in existing procedures utilized for flow balancing of the emergency equipment cooling water (EECW) system. The EECW system provided the heat sink for station safety-related heat loads including cooling for the residual heat removal (RHR) and core spray (CS) room coolers. The installed strainers on the EECW system are capable of filtering debris greater than 1/8 inch (.125 inches), potentially allowing debris less than 1/8 inch to pass through and clog downstream throttle valves. A clog in the throttle valves would prevent adequate flow from reaching safety-related heat exchangers unless procedural guidance or limitations prevented throttling valves to disk-to-seat clearances of less then 1/8 inch. The existing EECW flow balance procedure was inadequate in that it made no provision in the acceptance criteria to limit or evaluate minimum throttle valve seat/disc clearance, and the subsequent potential for increased flow obstruction, resulting from system flow balancing. This finding was entered into the licensees corrective action program as problem evaluation reports (PERs) 208374 and 208636. Planned corrective actions included a revision to EECW flow balancing procedures. The inspectors verified and discussed with the licensee existing indications that are available to alert the operator of potential clogging. This finding is more than minor because it affects the Mitigating Systems cornerstone objective of ensuring the availability, reliability, and operability of the RHR and CS pump room coolers to perform the intended safety function during a design basis event and the cornerstone attribute of Procedure Quality, i.e. Maintenance and Testing (Pre-event) Procedures. The team assessed this finding using the Significance Determination Process (SDP) and determined that the finding was of very low safety significance (Green) because the inspectors found no documented history of an actual loss of safety system function. This finding was reviewed for cross-cutting aspects and none were identified
05000259/FIN-2008003-03Browns Ferry2008Q2Failure to Identify and Correct Deficiencies in Degraded Flood Protection DoorsThe NRC identified a Green non-cited violation of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, for the licensees failure to identify and correct deficiencies in watertight doors that protect the safety-related Residual Heat Removal Service Water pumps and Emergency Equipment Cooling Water pumps from external flooding. The licensee issued work orders to correct the conditions and entered the issue into their corrective action program as Problem Evaluation Reports 133891 and 134346. This finding was more than minor because it affects the External Factors (Flood Hazard) attribute of the Mitigating Systems Cornerstone. It impacted the cornerstone objective of ensuring the availability, reliability, and operability of safety-related pumps to perform their intended safety function during a design basis flooding event. A Significance Determination Process Phase 3 analysis determined that the finding was of very low safety significance because of the low likelihood of the design basis flood. The finding was directly related to the cross-cutting aspect of procedural compliance of the work control component of the cross-cutting area of Human Performance. Mechanics were not complying with quarterly work orders and maintenance procedure to assure functionally of the watertight doors (H.4(b))
05000259/FIN-2007007-03Browns Ferry2007Q4Degraded Flood Protection Doors for the Intake Cooling StructureDuring system walkdown, the team observed degraded watertight doors at the intake cooling structure which houses the residual heat removal service water (RHRSW) and emergency equipment cooling water (EECW) pumps. Subsequent licensee evaluation of the four watertight doors determined that three of the four were degraded. With the doors closed, gaps up to 12 inch existed between the door seal and door frame. The licensee initiated work orders to repair the doors and initiated PER 133899. The UFSAR (Section 12.2.7.1.2) states in part that the doors provide flood protection against the probable maximum flood (PMF) of 572.5 feet. For the PMF, the licensee located a TVA corporate calculation (GEN-CEB-CDQ-0999-98-00-01) which states the PMF is 569.2 feet, not 572.5 feet. This item is unresolved pending the following: 1. The licensees acceptance of the 1998 calculation as their design basis for the PMF. 2. The inspectors review of the new design basis for the PMF. 3. Using the revised PMF, the inspectors review and inspection of the licensees evaluation of the potential impact of the degraded doors. This item is identified as URI 05000259/2007007-03, 05000260/2007007-03 and 05000296/2007007-03, Degraded Flood Protection Doors for the Intake Cooling Structure.
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